by Edward Fronczkowski, CPA
In 2016, the Department of Labor (DOL), Internal Revenue Service (IRS) and Pension Benefit Guaranty Corporation (PBGC) proposed significant revisions to Form 5500. These revisions will greatly expand the type and amount of information that is being collected. These changes included increased financial reporting for non-standard investments, more clear disclosure of fees and administrative expenses and a closer look at plan compliance. The biggest proposed change eliminates the small group (under 100 plan participants at the beginning of the plan year) exception from filing the Form 5500. All small group health plans would be required to file the Form 5500. Efforts to finalize the revisions, however, which were originally proposed to take effect for plan year 2019 reporting, appear to be on hold for now as the IRS and DOL have not met on this topic since late 2017. We will continue to monitor this situation and will communicate any new developments in our newsletter. If you are not currently receiving our newsletter, please let us know so that we can add you to the distribution list.
The 2018 form 5500 contains a few changes. The most significant is an increase in administrative penalties. The maximum penalty for incorrectly or not filing Form 5500 is rising to $2,140 per day, up from $2,097 per day, for penalties assessed after Jan. 2, 2018, and for associated violations that occurred after Nov. 2, 2015.
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